Securities & Exchange Commission v. Platinum Management (NY) LLC, et al.

Platinum Receivership


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Court Docket

United States District Court
Southern District of New York
In re Platinum-Beechwood Litigation
Case No. 1:18-cv-06658-JSR


View Dockets:1-50 | 51-100 | 101-150 | 151-200 | 201-250 | 251-300 | 301-350 | 351-400
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 801-850 | 851-900 | 901-950 | 951-1000 | 1001-1050 | 1051-1100 | 1101-1104

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Date Court Document Number Description
02/15/2019 151 REPLY MEMORANDUM OF LAW in Support re: 131 MOTION to Dismiss the First Amended Complaint. . Document filed by Huberfeld Family Foundation. (Chase, Donald) (Entered: 02/15/2019)
02/15/2019 152 REPLY MEMORANDUM OF LAW in Support re: 134 MOTION to Dismiss First Amended Complaint. . Document filed by Estate of Uri Landesman. (Breslin, Eric) (Entered: 02/15/2019)
02/15/2019 153 REPLY MEMORANDUM OF LAW in Support re: 120 MOTION to Dismiss the First Amended Complaint for Failure to State a Claim. . Document filed by Kevin Cassidy, Michael Nordlicht. (Doherty, Therese) (Entered: 02/15/2019)
02/15/2019 154 REPLY MEMORANDUM OF LAW in Support re: (192 in 1:18-cv-10936-JSR) MOTION to Dismiss the First Amended Complaint., (117 in 1:18-cv-06658-JSR) MOTION to Dismiss the First Amended Complaint. . Document filed by Daniel Saks. Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-10936-JSR(Schwartz, Wendy) (Entered: 02/15/2019)
02/15/2019 155 REPLY MEMORANDUM OF LAW in Support re: 124 MOTION to Dismiss the First Amended Complaint, dated 2/4/2019. dated 2/15/2019. Document filed by David Steinberg. (Hodges, David) (Entered: 02/15/2019)
02/15/2019 156 REPLY MEMORANDUM OF LAW in Support re: (106 in 1:18-cv-06658-JSR) MOTION to Dismiss First Amended Complaint., (182 in 1:18-cv-10936-JSR) MOTION to Dismiss First Amended Complaint. . Document filed by David Bodner. Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-10936-JSR(Lauer, Eliot) (Entered: 02/15/2019)
02/15/2019 157 REPLY MEMORANDUM OF LAW in Support re: (187 in 1:18-cv-10936-JSR) MOTION to Dismiss First Amended Complaint., (112 in 1:18-cv-06658-JSR) MOTION to Dismiss First Amended Complaint. . Document filed by Beechwood Trust No. 10, Beechwood Trust No. 11, Beechwood Trust No. 12, Beechwood Trust No. 13, Beechwood Trust No. 14, Beechwood Trust No. 7, Beechwood Trust No. 8, Beechwood Trust No. 9. Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-10936-JSR(Lauer, Eliot) (Entered: 02/15/2019)
02/15/2019 158 REPLY MEMORANDUM OF LAW in Support re: 137 MOTION to Dismiss First Amended Complaint. . Document filed by David Ottensoser. (Creizman, Eric) (Entered: 02/15/2019)
02/21/2019 159 NOTICE OF APPEARANCE by Ira S. Lipsius on behalf of B Asset Manager II LP, B Asset Manager LP, BAM Administrative Services LLC, Beechwood Bermuda International Ltd., Beechwood Bermuda Ltd., Beechwood Re Holdings, Inc., Beechwood Re Investments, LLC, Beechwood Re Ltd., Moshe M. Feuer, Feuer Family Trust, Scott Taylor, Taylor-Lau Family Trust. (Lipsius, Ira) (Entered: 02/21/2019)
02/21/2019 160 REPLY MEMORANDUM OF LAW in Support re: 122 MOTION to Dismiss . . Document filed by Murray Huberfeld. (Daniels, Jeffrey) (Entered: 02/21/2019)
02/22/2019 161 NOTICE OF APPEARANCE by Therese Marie Doherty on behalf of Meadows Capital LLC. Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-10936-JSR(Doherty, Therese) (Entered: 02/22/2019)
02/22/2019 162 MOTION to Dismiss (Notice of Joinder to Motions to Dismiss). Document filed by Meadows Capital LLC.(Doherty, Therese) (Entered: 02/22/2019)
02/22/2019 163 MEMORANDUM OF LAW in Support re: 162 MOTION to Dismiss (Notice of Joinder to Motions to Dismiss). . Document filed by Meadows Capital LLC. (Doherty, Therese) (Entered: 02/22/2019)
02/25/2019 164 ORDER FOR ADMISSION PRO HAC VICE in case 1:18-cv-06658-JSR; granting (245) Motion for John L. Brownlee to Appear Pro Hac Vice in case 1:18-cv-10936-JSR. (Signed by Judge Jed S. Rakoff on 2/22/2019) Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-10936-JSR (jwh) (Entered: 02/25/2019)
02/27/2019 NOTICE of Argument set for March 6, 2019 at 3;30pm. on Trott's Motion to Dismiss. (Kotowski, Linda) (Entered: 02/27/2019)
03/01/2019 165 NOTICE OF APPEARANCE by Erik Bradley Weinick on behalf of Melanie L. Cyganowski, Platinum Partners Credit Opportunities Fund (BL) LLC, Platinum Partners Credit Opportunities Fund (TE) LLC, Platinum Partners Credit Opportunities Fund International (A) Ltd., Platinum Partners Credit Opportunities Fund International Ltd., Platinum Partners Credit Opportunities Fund LLC. (Weinick, Erik) (Entered: 03/01/2019)
03/01/2019 Minute Entry for proceedings held before Judge Jed S. Rakoff: Oral Argument held on 3/1/2019 re: 87 MOTION to Dismiss the Second Amended Complaint. filed by B Asset Manager, L.P., Moshe M. Feuer, Beechwood Bermuda International, Ltd., Dhruv Narain, Beechwood Re Investments, LLC, Beechwood Re Ltd., Scott A. Taylor. A Contempt Hearing is scheduled for March 26, 2019 at 11:00am. (Kotowski, Linda) (Entered: 03/25/2019))
03/01/2019 ***DELETED DOCUMENT. Minute entry scheduling Contempt Hearing for March 26, 2019. The document was incorrectly filed in this case. (Landers, Rigoberto) (Entered: 03/25/2019)
03/01/2019 Minute Entry for proceedings held before Judge Jed S. Rakoff: Oral Argument held on 3/1/2019 re: 87 MOTION to Dismiss the Second Amended Complaint. filed by B Asset Manager, L.P., Moshe M. Feuer, Beechwood Bermuda International, Ltd., Dhruv Narain, Beechwood Re Investments, LLC, Beechwood Re Ltd., Scott A. Taylor. (Kotowski, Linda) (Entered: 03/25/2019)
03/07/2019 166 NOTICE OF APPEARANCE by Andrew S. Halpern on behalf of Melanie L. Cyganowski, Platinum Partners Credit Opportunities Fund (BL) LLC, Platinum Partners Credit Opportunities Fund (TE) LLC, Platinum Partners Credit Opportunities Fund International (A) Ltd., Platinum Partners Credit Opportunities Fund International Ltd., Platinum Partners Credit Opportunities Fund LLC. (Halpern, Andrew) (Entered: 03/07/2019)
03/08/2019 167 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent CNO Financial Group, Inc. for Bankers Conseco Life Insurance Company, Bankers Conseco Life Insurance Company. Document filed by Bankers Conseco Life Insurance Company.Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-12018-JSR(Kaiser, Adam) (Entered: 03/08/2019)
03/08/2019 168 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent CNO Financial Group, Inc. for Washington National Insurance Company, Washington National Insurance Company. Document filed by Washington National Insurance Company.Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-12018-JSR(Kaiser, Adam) (Entered: 03/08/2019)
03/08/2019 169 MOTION to Dismiss the Complaint. Document filed by Bankers Conseco Life Insurance Company, Washington National Insurance Company.(Kaiser, Adam) (Entered: 03/08/2019)
03/08/2019 170 MEMORANDUM OF LAW in Support re: 169 MOTION to Dismiss the Complaint. . Document filed by Bankers Conseco Life Insurance Company, Washington National Insurance Company. (Kaiser, Adam) (Entered: 03/08/2019)
03/08/2019 171 DECLARATION of Jenna C. Polivy in Support re: 169 MOTION to Dismiss the Complaint.. Document filed by Bankers Conseco Life Insurance Company, Washington National Insurance Company. (Attachments: # 1 Exhibit A (Part 1), # 2 Exhibit A (Part 2), # 3 Exhibit A (Part 3), # 4 Exhibit A (Part 4), # 5 Exhibit B (Part 1), # 6 Exhibit B (Part 2), # 7 Exhibit B (Part 3), # 8 Exhibit B (Part 4), # 9 Exhibit B (Part 5), # 10 Exhibit C, # 11 Exhibit D)(Polivy, Jenna) (Entered: 03/08/2019)
03/08/2019 172 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate Blackrock, Inc. for CNO Financial Group, Inc., CNO Financial Group, Inc.. Document filed by CNO Financial Group, Inc..Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-12018-JSR(Kaiser, Adam) (Entered: 03/08/2019)
03/08/2019 173 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent CNO Financial Group, Inc. for 40/86 Advisors, Inc., 40/86 Advisors, Inc.. Document filed by 40/86 Advisors, Inc..Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-12018-JSR(Kaiser, Adam) (Entered: 03/08/2019)
03/08/2019 174 MOTION to Dismiss the Complaint. Document filed by 40/86 Advisors, Inc., CNO Financial Group, Inc.. Responses due by 3/22/2019(Kaiser, Adam) (Entered: 03/08/2019)
03/08/2019 175 MEMORANDUM OF LAW in Support re: 174 MOTION to Dismiss the Complaint. . Document filed by 40/86 Advisors, Inc., CNO Financial Group, Inc.. (Kaiser, Adam) (Entered: 03/08/2019)
03/08/2019 176 DECLARATION of Karl W. Kindig in Support re: 174 MOTION to Dismiss the Complaint.. Document filed by 40/86 Advisors, Inc., CNO Financial Group, Inc.. (Kaiser, Adam) (Entered: 03/08/2019)
03/11/2019 177 STIPULATION AND ORDER EXTENDING TIME TO RESPOND TO COMPLAINT: IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned attorneys for the parties to the above-captioned action, that the time within which Katz may move, answer, or otherwise respond to the First Amended Complaint, or any further amended complaint in the Trott Action, is hereby extended up to and including the date to be set by the Court for the filing of motions to dismiss on grounds other than group pleading. IT IS FURTHER STIPULATED AND AGREED that no provision of this Stipulation and Order shall be construed as a waiver of any party's claims or defenses, which each party reserves. There has been no previous request for an extension of time for Katz to respond to the Complaint or First Amended Complaint. SO ORDERED. (Signed by Judge Jed S. Rakoff on 3/10/2019) Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-10936-JSR(rro) (Entered: 03/11/2019)
03/11/2019 178 STIPULATION AND ORDER EXTENDING TIME TO RESPOND TO COMPLAINT: IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned attorneys for the parties to the above-captioned action, that the time within which Katz may move, answer, or otherwise respond to the First Amended Complaint, or any further amended complaint in the Trott Action, is hereby extended up to and including the date to be set by the Court for the filing of motions to dismiss on grounds other than group pleading. IT IS FURTHER STIPULATED AND AGREED that no provision of this Stipulation and Order shall be construed as a waiver of any party's claims or defenses, which each party reserves. There has been no previous request for an extension of time for Katz to respond to the Complaint or First Amended Complaint. SO ORDERED. (Signed by Judge Jed S. Rakoff on 3/10/2019) (jca) (Entered: 03/11/2019)
03/11/2019 179 MEMORANDUM OF LAW in Opposition re: (253 in 1:18-cv-10936-JSR) MOTION to Dismiss (Notice of Joinder to Motions to Dismiss). . Document filed by Platinum Partners Value Arbitrage Fund L.P., Christopher Smith, Martin Trott. Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-10936-JSR(Bixter, Richard) (Entered: 03/11/2019)
03/11/2019 180 SUPPLEMENTAL RESPONSE in Opposition To Moving Defendants Motions To Dismiss. Document filed by Platinum Partners Value Arbitrage Fund L.P., Christopher Smith, Martin Trott. (Attachments: # 1 Exhibit 1- email chain, dated June 2 and 3, 2009, between Gilad Kalter and Gordon R. Diamond, # 2 Exhibit 2 - collection of emails that confirms that Mr. Diamond regularly invested with Huberfeld, # 3 Exhibit 3 - email thread dated January 31 and February 1, 2013)(Bixter, Richard) (Entered: 03/11/2019)
03/13/2019 181 RESPONSE to Motion re: 109 MOTION to Dismiss . . Document filed by GRD Estates Ltd.. (Penn, John) (Entered: 03/13/2019)
03/15/2019 182 REPLY MEMORANDUM OF LAW in Support re: 162 MOTION to Dismiss (Notice of Joinder to Motions to Dismiss). . Document filed by Meadows Capital LLC. (Doherty, Therese) (Entered: 03/15/2019)
03/15/2019 183 ORDER terminating (103) Motion to Dismiss; terminating (106) Motion to Dismiss; terminating (109) Motion to Dismiss; terminating (112) Motion to Dismiss; terminating (117) Motion to Dismiss; terminating (120) Motion to Dismiss; terminating (122) Motion to Dismiss; terminating (127) Motion to Dismiss; terminating (134) Motion to Dismiss; terminating (137) Motion to Dismiss; terminating (139) Motion to Dismiss; terminating (162) Motion to Dismiss in case 1:18-cv-06658-JSR; terminating (172) Motion to Dismiss; terminating (175) Motion to Dismiss; terminating (180) Motion to Dismiss; terminating (182) Motion to Dismiss; terminating (184) Motion to Dismiss; terminating (187) Motion to Dismiss; terminating (192) Motion to Dismiss; terminating (194) Motion to Dismiss; terminating (199) Motion to Dismiss; terminating (206) Motion to Dismiss; terminating (209) Motion to Dismiss; terminating (214) Motion to Dismiss; terminating (253) Motion to Dismiss in case 1:18-cv-10936-JSR: After receiving full briefing from all parties, the Court held oral argument on March 6 and 7, 2019. Upon consideration, the Court hereby grants defendants' motions in the following respects: The Estate of Jules Nordlicht, FCBA Trust, Morris Fuchs, Barbara Nordlicht, Aaron Parnes, Sarah Parnes, Shmuel Fuchs Foundation, Solomon Werdiger, GRD Estates Ltd., Meadows Capital LLC, Leon Meyers, Platinum FI Group, LLC, Rockwell Fulton Capital L.P., and Ditmas Park Capital L.P.: Only the Ninth Count of the FAC (aiding and abetting breach of fiduciary duties) and the Tenth Count (aiding and abetting fraud) are dismissed. Beechwood Capital Group LLC: All claims are dismissed. BBLN-PEDCO Corp.: All claims are dismissed. BHLN-PEDCO Corp.: All claims are dismissed. Beechwood Trust Nos. 7-14: All claims are dismissed. David Bodner: Only the Fourteenth Count (unjust enrichment) is dismissed. Daniel Saks: Only the Fourteenth Count (unjust enrichment) is dismissed. Murray Huberfeld: Only the Fourteenth Count (unjust enrichment) is dismissed. David Ottensoser: Only the Fourteenth Count (unjust enrichment) is dismissed. The Court denies defendants' motions in all other respects. The motions of those defendants not mentioned above (B Asset Manager II LP, Bernard Fuchs, David Levy, Kevin Cassidy, Michael Nordlicht, and The Estate of Uri Landesman) are denied in their entirety. An opinion explaining the Court's ruling will issue in due course. As a final matter, the Court has yet to address the discovery obligations of defendants in this case who are also standing trial, or are set to stand trial, in a related criminal matter in the Eastern District of New York. The Court has decided that these defendants will not be excused from document production in this case, but they will otherwise be excused from all discovery obligations until the completion of their trial. The deadline for these defendants to answer or move to dismiss (if they have not done so already) is likewise extended until two weeks following the completion of their trial. For all other defendants, any further motions to dismiss must be filed - like the motions decided in the instant Order - as part of a single round. All interested parties are directed to convene a joint conference call to chambers to set a briefing schedule on this second round of motions. The Clerk is directed to close the entries at docket numbers 172, 175, 180, 182, 184, 187, 192, 194, 199, 206, 209, 214, and 253. (Signed by Judge Jed S. Rakoff on 3/15/2019) Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-10936-JSR (jwh) (Entered: 03/15/2019)
03/15/2019 184 ORDER granting in part and denying in part 87 Motion to Dismiss: After receiving full briefing from each side, the Court held oral argument on March 1, 2019. Upon consideration, the Court hereby grants defendants' motion in the following respects: SHIP's RICO claims are dismissed as to all defendants. SHIP's fraud and constructive fraud claims are dismissed only as to Narain. SHIP's unjust enrichment claim is dismissed only as to Narain, Beechwood Re Ltd., B Asset Manager, L.P., Beechwood Bermuda International Ltd., and Beechwood Re Investments, LLC. The Court denies defendants' motion in all other respects. An opinion explaining the Court's ruling will issue in due course. The Clerk is directed to close the entry at docket number 87. (Signed by Judge Jed S. Rakoff on 3/15/2019) (jwh) (Entered: 03/15/2019)
03/18/2019 185 PROPOSED ORDER. Document filed by Bankers Conseco Life Insurance Company, Washington National Insurance Company. (Kaiser, Adam) Proposed Order to be reviewed by Clerk's Office staff. (Entered: 03/18/2019)
03/18/2019 ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. 185 Proposed Order was reviewed and approved as to form. (km) (Entered: 03/18/2019)
03/19/2019 186 TRANSCRIPT of Proceedings re: CONFERENCE held on 3/1/2019 before Judge Jed S. Rakoff. Court Reporter/Transcriber: Eve Giniger, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 4/9/2019. Redacted Transcript Deadline set for 4/19/2019. Release of Transcript Restriction set for 6/17/2019.(McGuirk, Kelly) (Entered: 03/19/2019)
03/19/2019 187 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERNECE proceeding held on 3/1/19 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) (Entered: 03/19/2019)
03/19/2019 188 NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO F.R.C.P. 41(a)(1)(A)(i): Pursuant to F.R.C.P. 41(a)(l)(A)(i) of the Federal Rules of Civil Procedure, plaintiffs, by and through undersigned counsel, hereby give notice that the above-captioned action is voluntarily dismissed without prejudice against defendant David Steinberg. SO ORDERED. (David Steinberg terminated.) (Signed by Judge Jed S. Rakoff on 3/18/2019) (rro) (Entered: 03/19/2019)
03/20/2019 189 ORDER GRANTING MOTION TO FILE UNDER SEAL: This matter having come before the Court on an application to file defendants Bankers Conseco Life Insurance Company and Washington National Insurance Company's Answer with Crossclaims and Third-Party Claims Under Seal (the "Answer"), and the Court having been duly advised, now finds said motion is hereby GRANTED. A redacted version of the Answer will be filed electronically. IT IS HEREBY ORDERED that the unredacted version of the Answer shall be maintained under seal. (Signed by Judge Jed S. Rakoff on 3/19/2019) Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-12018-JSR(jwh) (Entered: 03/20/2019)
03/20/2019 190 ANSWER to 84 Amended Complaint,., COUNTERCLAIM against Senior Health Insurance Company of Pennsylvania. Document filed by Beechwood Re Ltd., Moshe M. Feuer, Beechwood Re Investments, LLC, Scott A. Taylor, Dhruv Narain, B Asset Manager, L.P., Beechwood Bermuda International, Ltd.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15)(Harris, Mark) (Entered: 03/20/2019)
03/20/2019 191 MOTION for Summary Judgment Notice of Motion for Partial Summary Judgment by the Beechwood Parties. Document filed by B Asset Manager, L.P., Beechwood Bermuda International, Ltd., Beechwood Re Investments, LLC, Beechwood Re Ltd., Moshe M. Feuer, Dhruv Narain, Scott A. Taylor.(Harris, Mark) (Entered: 03/20/2019)
03/20/2019 192 MEMORANDUM OF LAW in Support re: 191 MOTION for Summary Judgment Notice of Motion for Partial Summary Judgment by the Beechwood Parties. . Document filed by B Asset Manager, L.P., Beechwood Bermuda International, Ltd., Beechwood Re Investments, LLC, Beechwood Re Ltd., Moshe M. Feuer, Dhruv Narain, Scott A. Taylor. (Harris, Mark) (Entered: 03/20/2019)
03/20/2019 193 DECLARATION of Steven H. Holinstat in Support re: 191 MOTION for Summary Judgment Notice of Motion for Partial Summary Judgment by the Beechwood Parties.. Document filed by B Asset Manager, L.P., Beechwood Bermuda International, Ltd., Beechwood Re Investments, LLC, Beechwood Re Ltd., Moshe M. Feuer, Dhruv Narain, Scott A. Taylor. (Attachments: # 1 Exhibit A (Part 1), # 2 Exhibit A (Part 2), # 3 Exhibit A (Part 3), # 4 Affidavit Declaration of Naima L. Farrell, # 5 Affidavit Declaration of John E. Jureller, Jr.)(Harris, Mark) (Entered: 03/20/2019)
03/20/2019 194 RULE 56.1 STATEMENT. Document filed by B Asset Manager, L.P., Beechwood Bermuda International, Ltd., Beechwood Re Investments, LLC, Beechwood Re Ltd., Moshe M. Feuer, Dhruv Narain, Scott A. Taylor. (Harris, Mark) (Entered: 03/20/2019)
03/20/2019 Minute Entry for proceedings held before Judge Jed S. Rakoff: Telephone Conference held on 3/20/2019. Oral argument is scheduled for a Motion for Advancement of Attorneys Fees on May 1, 2019 at 4:00pm. (Kotowski, Linda) (Entered: 03/22/2019)
03/22/2019 195 PROPOSED STIPULATION AND ORDER. Document filed by Naftali Manela. (Cohen, Adam) (Entered: 03/22/2019)
03/22/2019 196 MEMORANDUM OF LAW in Opposition re: 169 MOTION to Dismiss the Complaint. filed by Bankers Conseco Life Insurance Company and Washington National Insurance Company. Document filed by Melanie L. Cyganowski, Platinum Partners Credit Opportunities Fund (BL) LLC, Platinum Partners Credit Opportunities Fund (TE) LLC, Platinum Partners Credit Opportunities Fund International (A) Ltd., Platinum Partners Credit Opportunities Fund International Ltd., Platinum Partners Credit Opportunities Fund LLC. (Weinick, Erik) (Entered: 03/22/2019)
03/22/2019 197 MEMORANDUM OF LAW in Opposition re: 174 MOTION to Dismiss the Complaint. filed by Defendants CNO Financial Group, Inc. and 40/86 Advisors, Inc.. Document filed by Melanie L. Cyganowski, Platinum Partners Credit Opportunities Fund (BL) LLC, Platinum Partners Credit Opportunities Fund (TE) LLC, Platinum Partners Credit Opportunities Fund International (A) Ltd., Platinum Partners Credit Opportunities Fund International Ltd., Platinum Partners Credit Opportunities Fund LLC. (Weinick, Erik) (Entered: 03/22/2019)
03/22/2019 198 DECLARATION of Erik B. Weinick in Opposition re: 169 MOTION to Dismiss the Complaint., 174 MOTION to Dismiss the Complaint.. Document filed by Melanie L. Cyganowski, Platinum Partners Credit Opportunities Fund (BL) LLC, Platinum Partners Credit Opportunities Fund (TE) LLC, Platinum Partners Credit Opportunities Fund International (A) Ltd., Platinum Partners Credit Opportunities Fund International Ltd., Platinum Partners Credit Opportunities Fund LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G)(Weinick, Erik) (Entered: 03/22/2019)
03/25/2019 199 PROPOSED PROTECTIVE ORDER. Document filed by 40/86 Advisors, Inc., Bankers Conseco Life Insurance Company, CNO Financial Group, Inc., Washington National Insurance Company. (Aerni, John) (Entered: 03/25/2019)
03/25/2019 200 STIPULATION AND ORDER: IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned attorneys for the parties, that Manela's discovery obligations and time to respond to the Amended Complaint should be the same as the E.D.N.Y. Defendants. Accordingly, it is agreed that Manela shall respond to document requests in this case, but Manela will otherwise be excused from all discovery obligations until the completion of the trial in the related criminal matter in the Eastern District of New York, and it is agreed that the deadline for Manela to answer or move to dismiss the Amended Complaint is extended until two weeks following completion of the trial. IT IS FURTHER STIPULATED AND AGREED, that no provision of this Stipulation and Order shall be construed as a waiver of any party's claims or defenses, which each party reserves. SO ORDERED. (Signed by Judge Jed S. Rakoff on 3/22/2019) Filed In Associated Cases: 1:18-cv-06658-JSR, 1:18-cv-10936-JSR(ne) (Entered: 03/25/2019)